Sulfuryl fluoride: Emergency Letter to Farm Bill Conferee Leaders

WE HAVE AN EMERGENCY! As we write this our food is under threat for containing very high levels of fluoride from the use of Sulfuryl fluoride as a food fumigant and we need your help.

A compromise meeting of Senate and House members is taking place today to negotiate the final language in the Farm Bill. The House version includes a provision (see below) requiring the EPA to provide Congress with a study of the economic impact of the phase-out. This real purpose of the study is to prevent the implementation of EPA’s proposed phase-out of Sulfuryl fluoride that Dow AgroSciences, their lobbyists and Congressional lapdogs have worked hard to torpedo.

We ask that you sign the following letter and to call, fax or email the Congressional conferees working on this.

THE LETTER

Dear Honorable Farm Bill Conferee Leaders:

The Fluoride Action Network (FAN) has studied Sulfuryl fluoride since 2001 when Dow AgroSciences (DOW) first petitioned the US EPA to approve it as a food fumigant. Previously, DOW campaigned hard in the US and Europe for using this significantly toxic substance as the replacement food fumigant to ozone-destroying methyl bromide (also manufactured by DOW). The majority of EU countries decided not to use sulfuryl fluoride and the few that do, use it only in EMPTY warehouses and mills, unlike the U.S., that allows food to be in these facilities during fumigation.

We urge you to reject the proposed study (Sec. 9016) as it is wasteful effort delaying protections to our most vulnerable, and interferes with EPA’s role to carry out its legal duties under the Food Quality Protection Act (FQPA). We urge you to stand with the scientists at U.S. EPA’s Pesticides Division who ultimately did the right thing to protect public health.

These are our reasons for rejecting this study:

• The FQPA, passed by Congress in 1996, was meant to provide stronger protections for infants and children from pesticides. FQPA mandated that the aggregate exposure to the active pesticide ingredient should not, in effect, exceed EPA’s safe reference dose. This is a good Act that needs Congressional protection from corporate interests. If anything, the Act should be strengthened, not weakened.

• The Sulfuryl fluoride case is the very first time that FQPA’s aggregate exposure has been cited to end the use of a pesticide. The US EPA’s Pesticide division spent ten years assessing the science and the substantive arguments put forward by the Objectors (Environmental Working Group, Beyond Pesticides, and FAN). In the end, they agreed with the Objectors and correctly proposed a phase-out of this fumigant. We urge our representatives to not waste taxpayers time and money in a study that will delay protections to the health of those they represent.

• In the case of Sulfuryl fluoride, the active ingredient is fluoride, as Sulfuryl fluoride breaks down rapidly to fluoride in the human body and in food. A 2010 report by the CDC found that 41% of 12-15 year olds had dental fluorosis, a condition due to overexposureto fluoride (Beltram et al[1]). A 2006 report by the National Research Council of the National Academies (NRC) noted that infants were being overexposedto fluoride (as well as other population subsets).

• The NRC report in 2006[2] stated for the first time that fluoride is an endocrine disruptor. The report also found that EPA’s Maximum Contaminant Level of 4 ppm of fluoride in drinking water is not protective of human health, and that fluoride can affect the brain.

• All the Sulfuryl fluoride animal neurotoxicity studies performed by DOW reported severe and rare effects on the brain – particularly the dissolution of cell architecture.

• Since the NRC report, FAN has paid for the professional translations of approximately 25 mainly Chinese studies that have reported an association of fluoride exposure and a reduction in children’s IQ (http://fluoridealert.org/studies/brain01/). The important fact these studies present is that there is not an adequate margin of safety in the current fluoride dosing and overdosing of America’s children.

[2] National Research Council of the National Academies. 2006. Fluoride in Drinking Water: A Scientific Review of EPA’s Standards. The National Academies Press, Washington, DC.

The Proposed Study included in the House version of the Farm Bill:

SEC. 9016. Not later than two years after the date of enactment of this Act, the Administrator of the Environmental Protection Agency, in conjunction with the Secretary of Agriculture, shall submit to the Committee on Agriculture of the House of Representatives a report on the potential economic and public health effects that would result from finalization of the proposed order published in the January 19, 2011, Federal Register (76 Fed. Reg. 3422) pertaining to the pesticide sulfuryl fluoride, including the anticipated impacts of such finalization on the production of an adequate, wholesome, and economical food supply and on farmers and related agricultural sectors.http://www.gpo.gov/fdsys/pkg/BILLS-113hr2642ih/pdf/BILLS-113hr2642ih.pdf_____________________________See all FAN Bulletins